Imbeciles

by Adam Cohen

  Strode gave Laughlin a brief synopsis of the facts of the case, but, as would be true at every stage of the proceedings, there were significant inaccuracies. Strode told Laughlin that the case concerned the sterilization of a “feeble-minded young woman nineteen years of age,” even though Carrie was not feebleminded, and she had just turned eighteen in July. He said Carrie’s mother was “also feeble-minded”—a dubious assertion, given the quality of the intelligence testing used to make that determination. And Strode told Laughlin that Carrie was “the mother of a feeble-minded child”—another falsehood, because Carrie’s daughter, Vivian, was just six months old and had never been tested in any way.

  Laughlin wrote back to Strode on October 3, his letter brimming with professional enthusiasm. He said he was “much interested” in hearing about the test case involving Virginia’s sterilization law. Laughlin noted that there was a similar challenge being posed to a statute in Michigan, and he provided the name of a lawyer in Detroit who had just completed a legal brief in the case. But Strode’s case appealed to him more because the Virginia eugenic sterilization law was newer and had been built “upon a thorough consideration of all previous legislation and litigation on the subject.”

  Laughlin made clear from the outset his hope that the Virginia case would reach the Supreme Court. The nation’s highest court could settle once and for all “just what a state can do in reference to enacting eugenical sterilization laws,” he said. If the case got that far, Laughlin was optimistic their side would prevail. The pro-eugenics forces had “thrashed out the matter so thoroughly”—and they had learned so much in the process about what was acceptable—that the Supreme Court “would sustain the essential elements of the Model Statute.”

  The facts of the Virginia case struck Laughlin as particularly “well selected.” He agreed with Dr. Priddy that Carrie and her family were just the sort of people who would help the state make its case for “the hereditary factor in the production of feeblemindedness.” The key, Laughlin told Strode, was that “both the immediate ancestor and the immediate offspring” were “feebleminded.” In his review of the eugenics literature, and the Eugenics Record Office fieldwork investigations of many hundreds of families, he could not “recall a single instance in which feeblemindedness appeared in the grandmother, the mother (the patient) and the child (three generations), by environmental or accidental causes.”

  Strode did not think it was necessary for Laughlin to travel to Virginia. It would be enough to submit written answers under oath to a set of questions sent to him by the lawyers. Laughlin agreed to do that—without meeting or examining Carrie or her family. To begin the scientific study necessary to offer his expert opinion, however, Laughlin wanted a more detailed description of the young woman’s lineage.

  Laughlin sent a memorandum outlining the sort of “first-hand field material” he would need for his eugenic analysis. He asked Strode for information on Carrie and her siblings, parents, aunts, uncles, cousins, grandparents, children, nephews, and nieces, as well as any “consorts who have married into this stock and who are the parents of any of the blood kin above mentioned.” For each of these, he wanted to know about parents, physical and mental development, literacy and mental test records, and a final quality: “social status with particular reference to the question of whether the individual has constituted a debit or credit to the social order.”

  Laughlin sent two tools the Eugenics Record Office had developed, a “Family Tree Folder” and a set of “Single Traits Sheets” for collecting and organizing the data. “If this material could be sent to me,” he said, “I should be very glad to analyze it in light of the present existing knowledge of the inheritance of mental defect.” Strode wrote to Dr. Priddy and asked him to collect the information Laughlin requested.

  After Laughlin signed on, Dr. Priddy followed up with a letter of his own on October 14. He offered Laughlin his assistance in assembling the necessary information. Dr. Priddy reminded Laughlin that the two men had previously been in contact. Virginia’s sterilization law had been drafted with the help of a copy of Eugenical Sterilization in the United States, “which you kindly gave me,” Dr. Priddy wrote.

  Dr. Priddy offered an idealized account of how Virginia’s sterilization law had come about. In his telling, it had not been the culmination of years of persistence by him and Dr. DeJarnette in the face of skepticism and rejection. Dr. Priddy told Laughlin the impetus had come from the top. At a meeting of the State Hospital Board the previous year, Dr. Priddy said, the governor had instructed him “to prepare and have pushed through the General Assembly of Virginia a Sterilization Law.” Dr. Priddy had then gone to Strode to draft a bill.

  In his letter, Dr. Priddy shared his philosophy about eugenics, sterilization, and the feebleminded, which was similar to Laughlin’s. Dr. Priddy explained his hope that he would be able to operate the colony on what he called the “clearing house” model: taking in feebleminded women, sterilizing them, and then setting them free to make room for more mentally defective women. It was a conception that closely tracked what Laughlin had recommended in his Battle Creek speech.

  As for the genealogical information Laughlin requested, Dr. Priddy’s attempts to trace Carrie’s lineage had proved frustrating. He had begun investigating Carrie’s family before Laughlin signed on as an expert. In mid-September, Dr. Priddy had written to Caroline Wilhelm, the Red Cross social worker who brought Carrie to the colony, asking for her help with eugenic fieldwork. He asked Wilhelm if she would “take Carrie Buck and her allied kin and get up the names of all defectives connected with the two sides” of the family “and make a report to me.”

  The investigation did not go as Dr. Priddy hoped. It got off to a slow start when the nurse assigned to the project phoned her supervisor to say she had lost Dr. Priddy’s letter. “‘Thought maybe it went down the back seat of the car,’” the supervisor informed Dr. Priddy of the news with evident irritation. She asked Dr. Priddy to send another copy of the letter.

  When the fieldwork finally began, it did not turn up much. “I have had the Red Cross people at work making these investigations but have gotten little more information than I already had,” Dr. Priddy told Strode. Dr. Priddy wrote to Laughlin that he was “very sorry” he could not “make you out a genealogical tree as you would like to have.” He offered a simple explanation for the lack of information. “This girl comes from a shiftless, ignorant and moving class of people,” and as result it was “impossible to get intelligent and satisfactory data.”

  What Dr. Priddy came up with was a tangle of relationships and possible relationships. He told Laughlin there were several inmates at the colony named Buck and others named Harlow (Emma’s maiden name was Harlowe). Dr. Priddy said “all of the Bucks and Harlows we have here descen[d] from the Bucks and Harlowes of Albemarle County” and that he believed “they are of the same stock.” There was “considerable doubt,” Dr. Priddy said, about whether Carrie was biologically a member of the Buck family. But he was more certain that Carrie was a Harlowe, through her mother. That “line of baneful heredity seems conclusive and unbroken,” he wrote.

  The picture of Carrie’s immediate family was not much clearer. Dr. Priddy told Laughlin that Carrie had two or three half brothers and half sisters, but they had been taken from Emma and adopted by non–family members. All he was able to learn, he said, about Richard Harlowe, Emma’s father, was that he had died of spinal trouble.

  Dr. Priddy offered more specific information about Carrie and Emma. Carrie, he reported, had been adopted by the Dobbses at age four, but was given up when her “moral delinquencies culminated in the illegitimate birth of” her daughter. Carrie attended school up to the sixth grade, and was “fairly helpful to the domestic work of the household under strict supervision.” Dr. Priddy said that as far as he understood, “there was no physical developmental or mental trouble” in “her early years.” He reported that Carrie had a “menta
l age of nine years,” and that she was “incapable of self support and restraint except under strict supervision.” He also offered his opinion, belied by photographs, that Carrie had a “rather badly formed face.”

  Laughlin did not get all of the information he wanted, and his elaborate eugenics research forms were never filled out. He did not personally meet Carrie or Emma or any other members of their family. He was satisfied, however, that based on the questionable information he received from Dr. Priddy, he knew enough to provide an expert opinion about Carrie and her family’s hereditary worth, and about whether Carrie should be sterilized.

  In a formal legal document that he signed before a notary public in Cold Spring Harbor on November 6, Laughlin answered Strode’s interrogatory questions. In response to the preliminary questions, Laughlin listed his credentials: assistant director of the Eugenics Record Office of the Carnegie Institution of Washington, and immediate supervisor of the office since it opened in 1910; supervisor of the annual Training Corps for eugenics field-workers; Expert Eugenics Agent for the House Committee on Immigration and Naturalization; Eugenics Associate of the Psychopathic Laboratory of the Municipal Court of Chicago; and author of Eugenical Sterilization in the United States, “a book of 502 pages,” he noted.

  After the background questions, Laughlin was asked to “give a short analysis of the hereditary nature of Carrie Buck.” He made clear that he was relying on “the truth of the following facts which were supplied by Superintendent A.S. Priddy.” With that qualification out of the way, he proceeded to explain why Carrie was mentally deficient, the probable parent of deficient children, and an appropriate subject for sterilization.

  Laughlin’s description of Carrie, based as it was on the sparse and not entirely accurate information Dr. Priddy had provided, was disconnected from her actual life. He testified that she had “mental defectiveness, evidenced by failure of mental development,” with a chronological age of eighteen but a mental age of just nine, according to the Stanford Revision of the Binet-Simon test. He described her history as having been marked by “social and economic inadequacy,” and stated that she had never been “self-sustaining.” Laughlin also testified that Carrie had a “record during life of immorality, prostitution, and untruthfulness,” though he did not back up these charges with any particulars. In a final disparaging detail, Laughlin included Dr. Priddy’s contention that Carrie, whom he had not met, had a “rather badly formed face.”

  Laughlin described Emma, whom he referred to by the archaic legal title “Mother of Propositus,” in even more negative terms. He reported that her chronological age was fifty-two and her mental age seven years and eleven months, based on the Stanford Revision of the Binet-Simon. Like her daughter, Emma had a record of “social and economic inadequacy,” Laughlin said, and had never been “self-sustaining.” Employing the same trio of disparaging words he used to describe Carrie, Laughlin said Emma had a record of “immorality, prostitution and untruthfulness.” He also said she had syphilis and at least one, but more likely three, illegitimate children.

  In his section on Carrie’s family, Laughlin offered another description taken from Dr. Priddy. “These people belong to the shiftless, ignorant, and worthless class of anti-social whites of the South,” he testified. Laughlin included the jumbled descriptions Dr. Priddy had given him of the Buck and Harlowe families and their possible relation to Carrie. He also repeated Dr. Priddy’s claim that Carrie might not be a Buck, and tracked his language about her Harlowe lineage, asserting that “the line of baneful heredity seems conclusive and unbroken on the side of her mother.”

  Laughlin’s most dubious assertions, again taken from Dr. Priddy, concerned Carrie’s daughter. He said Vivian, who was “about six months old,” was “considered feebleminded.” As support, Laughlin included a parenthetical that stated: “According to depositions of the Red Cross nurse, Miss Caroline E. Wilhelm, of Charlottesville, Va., in the proceeding committing Carrie Buck to the State Colony, Carrie Buck’s illegitimate baby gave evidence of mental defectiveness at an early age.”

  Laughlin’s statement was similar to the false claim that Dr. Priddy made at Carrie’s sterilization hearing, at which he had said that “according to the depositions” used in committing her to the colony, Carrie had “one illegitimate mentally defective child.” Wilhelm had said no such thing in the depositions used to commit Carrie to the colony—for the simple reason that when Carrie was committed, her daughter had not yet been born. It was a useful inaccuracy, however, because it allowed Laughlin to testify that there were three consecutive feebleminded generations in the Buck family, a pattern that he said in his first letter to Strode was, in his experience, always associated with hereditary mental defect.

  In the “Analysis of Facts” section of his interrogatory responses, Laughlin gave his opinion that Carrie’s feeblemindedness was hereditary. Feeblemindedness can be caused by environmental factors, he allowed, but he believed Carrie’s defect was “due, primarily, to inheritance.” In his experience, he said, a single feebleminded child appearing in an “apparently normal family” might be a result of environmental factors. However, “if the same mother has more than one feebleminded child, then, even in the absence of a more detailed pedigree record, the evidence weighs very heavily against the primary cause being environmental.” It was an odd analysis, because it bore no relation to the facts of Carrie’s case as he had just presented them. Laughlin was uncertain how many siblings Carrie had, but he did not say that any of them were feebleminded—and there was, at this point, no evidence that they were.

  Laughlin also purported to find evidence of Carrie’s feeblemindedness in her limited educational achievements. He noted that at the age of four she had been taken from “the bad environment furnished by her mother” and “given a better environment by her adopted mother, Mrs. J.T. Do[bb]s.” Despite this improvement in environment, Laughlin said, Carrie was “able to attain only to the 6th grade in school.” Her failure to do better in school was, Laughlin testified, “typical . . . of a low-grade moron.”

  It was, once again, an odd and misleading analysis. Laughlin’s statement that Carrie “was able to attain only to the 6th grade in school” suggested that the failure to proceed further was hers. The truth was that Carrie was performing perfectly well in school, and only stopped her education because the Dobbses would not let her continue. There was, in fact, nothing about Carrie’s educational history that pointed to feeblemindedness.

  Laughlin then addressed a critical question under the statute: whether Carrie was likely to give birth to defective children. Carrie was clearly a “potential parent,” he said, because she had already given birth to a child. Given her own “feeblemindedness and moral delinquency,” and the evidence from her family history that her defects were hereditary, Laughlin said, she had to be considered a “potential parent of socially inadequate or defective offspring.”

  Another interrogatory question asked Laughlin to “give in brief outline the results of scientific investigations tending to show that feeblemindedness is likely to be transmitted to offspring from a feebleminded parent,” and to include illustrative cases if he desired. Laughlin presented the court with a sizable list, starting with chapter 8 of his own book, Eugenical Sterilization in the United States, in which he had “analyzed, so far as data would permit, the hereditary nature of the particular social inadequacy from which the subject of the particular test case was suffering.” In every case he analyzed in the chapter, he said, the evidence showed “beyond a reasonable doubt” that “the particular inadequacy was inborn.”

  In another question, Strode asked about a key provision he had written into the Virginia sterilization law: the requirement that sterilization be in the interest of both the patient and society. Laughlin gave his opinion that salpingectomy and vasectomy “have but little physiological effect other than sexual sterility.” On the positive side, he said, eugenic sterilization provided a cl
ear benefit to society. The state had to prevent individuals who were fertile and “socially inadequate because of feeblemindedness” or “other constitutional defect” from reproducing. There were, Laughlin said, two ways of doing this: (1) segregating them in an institution where they would be prevented from having intercourse; and (2) eugenic sterilization. “Modern eugenical sterilization,” he concluded, “is a force for the mitigation of race degeneracy which, if properly used, is safe and effective.”

  Finally, Laughlin was asked to “give any other information or testimony in regard to the general subject” he thought might be helpful to the court. Laughlin took the opportunity to say he had closely examined sterilization laws that had been enacted around the country. Virginia’s statute was “one of the best laws thus far enacted,” he said. It “avoided the principal eugenical and legal defects of previous statutes, and has incorporated into it the most effective eugenical features and the soundest legal principles of previous laws.”

  • • •

  It was agreed from the beginning that Laughlin would not have to travel to Virginia to research the case or to testify. His participation would be limited to the interrogatories he mailed in from Cold Spring Harbor. It would clearly help the case, however, to have an expert witness appear in court. In a letter to Strode, Laughlin suggested a colleague, Arthur Estabrook, who might be willing to make the trip. Strode was enthusiastic about the recommendation, and told Dr. Priddy he would write to Estabrook.

  Arthur Estabrook was a thirty-nine-year-old eugenics field researcher. He was not as prominent as Laughlin, but he was beginning to make a name for himself with his studies of hereditary defects in communities and individuals. Like Laughlin, Estabrook had come to eugenics from an academic background. He was born into a middle-class family in Leicester, Massachusetts, and earned bachelor’s and master’s degrees at nearby Clark University. After receiving a Ph.D. in biology from Johns Hopkins in 1910, Estabrook joined the Eugenics Record Office as one of its first employees. Estabrook quickly became adept at the art and science of eugenics research. He was on his way to becoming, as one study of his work pronounced him, “the most prolific eugenics field worker in the history of the movement.”